The ACR commented on what it called the flawed background section and design of a survey of physician work schedules under the Medicare fee schedule, hoping to intercept inaccuracies it says would skew results.
McGinty said radiology had been disadvantaged by a 2009 survey that she said included input from a low number of radiologists from a limited spectrum of positions.
"Those findings have now been incorporated, and led to very negative effects for radiology practices," said Dr. Geraldine McGinty, chair of the ACR Commission on Economics, to DOTmed News.
One comment in the letter expresses the ACR's confusion over the number of physicians in the survey. The survey states that it will gather information from 300 physicians "distributed over a limited number of specialties."
McGinty said it was unclear whether it would be surveying 300 physicians total, or 300 from each specialty. Either way, the ACR is concerned that it would not take subspecialties into account.
"For example, I do exclusively breasts now, so someone who spent time with me would not learn anything about neuroradiology," said McGinty.
Another comment referred to the survey's assertion that imaging has been rapidly growing in recent years, when in fact it peaked in 2006 and had declined 21 percent by 2010, the letter says.
The ACR also felt that the survey structure would not accurately capture the unpredictability of a radiologist's workday.
She pointed out that a radiologist might look at a study at different points throughout the day, rather than all at once, so "standing over a radiologist with a stopwatch" would not make sense as a way of tracking work schedules.
"We would like to make sure that this process is accurate, that it reflects the reality of what we do," said McGinty.
The survey is one of two projects from the Office of the Assistant Secretary for Planning and Evaluation (ASPE).